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Taxation Authority's Use of CUP Method Over TNMM for Some Transactions Lacks Merit in Transfer Pricing Case Review.

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....Transfer pricing adjustment - Majority of transactions have been accepted to be at arm's length price by the TPO by applying TNMM method, only in respect of few transactions, the TPO had applied CUP method. There is no merit in the order of TPO in this regard.....

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